Current Mitigation

Developers first choose a potential project site within the areas open for development on BLM-managed land. Second, the developer determines the facility size and location within the selected site. The developer frequently performs initial studies to determine the best design and layout to maximize energy generation, and may fund ecological surveys to determine the location and distribution of sensitive resources on site. The size and layout can be influenced and changed during the permitting approval process, although most developers make these decisions before submitting their application to the BLM, having already spent significant financial resources on their design.

Once an application has been submitted, developers typically will consult with the BLM about different options for design and layout.  While the BLM may suggest changes in layout or location to reduce the amount of ecological impacts on the site based on known resources, the initial financial investment may leave developers reluctant to make large changes or move the proposed placement of key infrastructure. Some developers consult early with the BLM in order to incorporate the agency’s recommendations before committing too many resources to a design that may require changes. While this may be preferable, it is currently not the typical progression of facility design and placement. Given the current decision-making process for facility location and placement, mitigation measures are therefore limited. An analysis of the BLM’s process for approving proposed facilities is included in the Recommendations section.